Approach to Risk Management

The Board of Directors is the ultimate decision-making entity at Cromwell Property Group . Day-to-day management of the Group’s affairs and implementation of agreed strategic objectives (including those in relation to Sustainability) are delegated by the Board to management, under the direction of the CEO, via the Delegation of Authority Policy.

Corporate Governance

Cromwell complies with the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations (3rd edition). Recommendation 7.4 requires listed entities to disclose the extent to which they have material exposure to economic, environmental and social sustainability risks, and how those risks are, and will be, managed.

Cromwell meets recommendation 7.4 through publishing this Sustainability Report, which provides stakeholders with a clear understanding of how Cromwell approaches sustainability and manages its business activities.

The Board operates in accordance with a written Board Charter and the governance framework is extensively detailed in the Corporate Governance Statement found at www.cromwellpropertygroup.com/securityholder-centre/corporate-governance.

As an Australian financial services licensee and the responsible entity of the Cromwell Diversified Property Trust, Cromwell Property Securities Limited has a robust compliance framework, which includes ongoing training, reporting, and testing. The Compliance Committee comprised of a majority of independent external members – monitors Cromwell’s compliance with the framework.  The Board receives regular reports from the Committee meets with the Audit and Risk Committee, with part of that meeting conducted without management being present.

Sustainability Governance

Cromwell’s sustainability framework has been approved by the CEO and responsibility for the framework has in turn been delegated by the CEO to the Chief Sustainability Officer and the Group Sustainability Committee.

The Group Sustainability Committee is responsible for reviewing economic, environmental and social topics, setting sustainability strategy and overseeing the delivery of Cromwell’s sustainability and corporate social responsibility policy. Regular progress reports are submitted to the Board as well as to the Audit and Risk Committee. The Group Sustainability Committee is also responsible for communicating with employees and other key stakeholders as well as overseeing production of the annual Sustainability Report and all sustainability activities.

Ethics and Grievances

Cromwell’s Code of Conduct sets out expectations for Directors and employees in relation to ethics, honesty and integrity, conflicts of interest or duty, fair dealing, protection and proper use of assets, and compliance with laws, regulations and policies.

Cromwell’s Whistle-blower Policy actively encourages and supports the reporting of any actual or suspected contraventions of Cromwell’s ethical standards or legal obligations. Cromwell has a Conflict of Interest Policy and a Related Party Policy, the latter of which requires Board/Board Committee approval for all related party transactions.

Cromwell’s people and operations are covered by local anti-corruption requirements. Cromwell Directors and employees receive an annual training package that covers compliance requirements, including the local anti-corruption regime.

In line with the Australian regulatory framework, the Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) compliance program requires an assessment of employees and all investors in our unlisted funds. AML/CTF requirements form part of the distribution agreement with our Australian distribution network, including financial advisers.

Cromwell complies with all requirements concerning marketing communications, including advertising,

promotion and sponsorships. All marketing communications must be approved to ensure compliance with the relevant regulations and voluntary codes.